The Relationship Between EU Legislation and International Instruments in the Field of Private International Law

1. Putting EU Legislation into Context. - 1.1. EU Agreements. - 1.2. Member States’ Agreements. - 1.3. Agreements Concluded by Member States in the Interest of the Union. - 2. A Relationship of Subordination, Interplay and Confrontation. - 2.1. Subordination. - 2.1.1. Grounds for Subordination. - 2.1.1.1. EU Agreements. - 2.1.1.2. Member States’ Agreements. - 2.1.1.3. Agreements Concluded by Member States in the Interest of the Union. - 2.1.2. Variations on the Theme. - 2.1.2.1. Sheer Primacy. - 2.1.2.2. Disconnection Clauses. - 2.1.2.3. Unilaterally Mitigated Primacy. - 2.2. Interplay. - 2.2.1. Convergence. - 2.2.1.1. Convergence by Reference. - 2.2.1.2. Convergence by Imitation. - 2.2.2. Combination. - 2.2.2.1. The Two-Tier Model. - 2.2.2.2. The Assimilation Model. - 2.3. Confrontation. - 3. The Increasingly Important External Dimension of EU Private International Law. - 3.1. The Broad Construction of the External Competence of the European Union by the Court of Justice. - 3.2. The Virtual Global Reach of EU Legislation. - 3.3. External Action and the Management of Brexit. - 4. How European is EU Private International Law?